These proposed regulations remove a provision of filing Form 5472, “Information Return of a 25% Foreign-Owned U. S. Corporation of a Foreign Corporation Engaged in a U. S. Trade of Business”, when the filer's income tax return will be late. Form 5472 will always be required to be filed with the filer's income tax return, by the due date (including extensions) of that return.

The proposed regulations allow a taxpayer to make an alternative simplified credit election for a tax year on an amended return.

The Office of Professional Responsibility (OPR) announces recent disciplinary sanctions involving attorneys, certified public accountants, enrolled agents, enrolled actuaries, enrolled retirement plan agents, and appraisers. These individuals are subject to the regulations governing practice before the Internal Revenue Service (IRS), which are set out in Title 31, Code of Federal Regulations, Part 10, and which are published in pamphlet form as Treasury Department Circular No. 230. The regulations prescribe the duties and restrictions relating to such practice and prescribe the disciplinary sanctions for violating the regulations.

This revenue procedure provides safe harbors for applying the general welfare exclusion to Indian tribal government programs that provide benefits to tribal members.

This notice provides that the Section 1603 Payment resulting from sequestration does not affect the amount of the Section 1603 Award or the basis of the specified energy property taken into account for purposes of determining the Section 1603 Award. Consequently, taxpayers may not partition the basis of property for which they receive a Section 1603 Award and claim a tax credit under section 45 or 48 of the Code on any part of the basis of the same property. Additionally, this notice provides that under section 48(d)(3)(B), taxpayers must reduce the basis of the specified energy property by 50 percent of the amount of the actual Section 1603 Payment.

The final and temporary regulations allow a taxpayer to make an alternative simplified credit election for a tax year on an amended return.

These regulations on filing Form 5472, “Information Return of a 25% Foreign-Owned U.S. Corporation of a Foreign Corporation Engaged in a U. S. Trade or Business” are substantially identical to 2011 temporary regulations (76 FR 333997, TD 9529, 2011–30 IRB 57).

This ruling provides that a nonstatutory stock option or a stock appreciation right (each, a stock right) granted by a nonqualified entity for purposes of section 457A is treated as exempt from section 457A, provided that the stock right is exempt from section 409A, and further provided that the stock appreciation right at all times by its terms must be settled, and is settled, in service recipient stock for purposes of section 409A. Notice 2009–8 amplified.

This revenue procedure provides safe harbors for applying the general welfare exclusion to Indian tribal government programs that provide benefits to tribal members.